EU Thematic Strategy on Air Pollution
The CEZ Group considers the revision of the Thematic Strategy On Air Pollution very useful. However, it must be stressed that any measures that might come into account have to be considered from the view of efficiency, feasibility and cost-effectiveness and tailored according the sector in question.
For that it is important to take into account potential overlapping fir the existing frameworks (both for air quality and climate change) as well as the progress made in different sectors.
The CEZ Group believes that strong carbon price signal is decisive. Therefore we recommend to align the discussion over the 2030 climate targets with the air quality requirements with climate targets being a basis. In this respect we consider the electrification of transport and household heating/cooling as the main challenge.
Action taken in order to reduce the drawbacks of black carbon is needed. In this respect we consider the implementation of the proposed climate change legislation (carbon tax) as a significant contribution. However, due to the currently limited knowledge and data on black carbon emissions, it would be premature to adopt binding national emission ceilings or targets for black carbon under the current revision of the NECD and the TSAP.
The emission reductions imposed by the Gothenburg Protocol require significant investments already planned. Any changes in the 2020 limits now would mean additional financial burden that was initially not foreseen. Thus the 2020 NEC ceiling should accentuate the Gothenburg Protocol commitments but should not go beyond them. We do support the introduction of flexibility mechanisms and with a 2030 timeframe in mind; mandatory interim targets in 2025 could be counterproductive.